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Controlled group - who adopts the SIMPLE IRA?

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Controlled group made of Holding Company and two wholly owned subsidiaries. The Holding Company has adopted the SIMPLE IRA and is making the 3% match for employees. Generally, with a qualified plan all three entities would adopt the same plan as participating employers and each individual subsidiary would make the contribution for their own employees. Holding Company doesn't even have any employees. Is this a problem the way they have set it up? It seems like each of the subsidiaries should have also adopted the SIMPLE IRA and that they should be paying their match on behalf of their employees. I seem to remember though that for tax deductibility purposes, a member of a controlled group may make contributions on behalf of other members. Any thoughts?

[This message has been edited by Dawn Hafner (edited 01-17-2000).]


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